Ruling 89-129

Consulting

You have inquired as to whether your consulting services are subject to the sales and use tax under Public Act No. 89-251 which amended the language of section 12-407(i)(J) to tax "business analysis, management, consulting and public relations services."

The facts presented to us are that you are the physician director of a firm that provides advice to attorneys. In that capacity, you review and analyze patient records for possible malpractice actions against health care practitioners. You research specific medical topics and translate your research into layman's terms for use by attorneys in malpractice, personal injury and product liability cases. You also locate expert witnesses in various medical specialties to provide expert testimony for subsequent litigation.

It is our opinion that your consulting services are not subject to tax under section 12-407(i)(J) of the Connecticut General Statutes, because these services do not constitute advice rendered with respect to the operation of a client's business.